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New Mexico Required NEMT Staff to Train on September 15, 2026 After a Federal Payment Audit
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On September 3, 2026, the New Mexico Health Care Authority (HCA) issued Supplement 26-05 to non-emergency medical transportation (NEMT) providers. Its Medical Assistance Division said a federal audit, the CMS Payment Error Rate Measurement (PERM) review, had found NEMT claims with incomplete records and with units that did not match the records.
In response, HCA set a mandatory virtual training for September 15, 2026, from 9:00 to 11:00 a.m. Mountain time, on documentation, billing, and payment rules for fee-for-service Medicaid members. All NEMT management and billing staff were required to attend. Each person had to register separately by 5:00 p.m. on September 9, and HCA said it would email the meeting link and training materials to those registered by September 11.
What the audit found
The supplement names two errors, each on a mileage code billed with the RD origin and destination modifier, residence to a diagnostic or treatment site.
| PERM error | Code | What went wrong |
|---|---|---|
| Improperly completed documentation (MR9) | T2001 RD, attendant or escort | The transportation log has a place to mark that an attendant rode along. It was not checked, and nothing in the written log named an attendant |
| Number of units (MR6) | A0100 RD, taxi per mile | The miles billed were fewer than the miles in the record, and the record needed to support the claim’s pricing was not provided |
The second error was an underbilled claim, and it still counted. Federal rule 42 CFR 431.960 defines a payment error as an overpayment or an underpayment, and lists missing documentation, insufficient documentation, and unit errors among the causes.
Both codes pay by the loaded mile. Under the schedule effective January 1, 2025, a taxi mile pays $2.06, up to $300 per one-way trip, and an attendant mile pays $0.71, up to $150 per one-way trip. The fee schedule says a physician must attest in writing that the attendant is needed.
Who it affects
The training was set to cover the rules for fee-for-service members, whose rides you bill to HCA directly. HCA says Native American members can always choose between a Turquoise Care health plan and fee-for-service. Health plan members ride through each plan’s vendor, whose own contract rules apply on top of the state rule. See the New Mexico state guide for each plan and vendor.
Why PERM matters to a small provider
CMS measures improper Medicaid payments in each state once every three years. It says the rate is not a fraud rate, only a count of payments that did not meet the rules. New Mexico is in cycle 1, and its next review, for reporting year 2028, samples claims from July 1, 2026 through June 30, 2027. CMS lists April 1, 2027 to April 15, 2028 as the window for records requests.
That means claims you bill now can be picked. If yours is, federal rule 42 CFR 431.970 gives you 75 calendar days to send the records, and 14 days to answer any request for more. States must return the federal share of overpayments found (42 CFR 431.1002). Under 8.302.1 NMAC, a service your records do not support is subject to recoupment. See Medicaid audits for NEMT.
What New Mexico’s rules require in your records
- Enough detail to back every unit. Records must show the date, time, member’s name, and the level and quantity of service (8.302.1.17 NMAC).
- Six years. Keep medical and business records for at least six years from the payment date. See NEMT record retention.
- Loaded miles only. HCA pays nothing for any part of a trip without the member in the vehicle (8.324.7.16 NMAC). The fee schedule says to bill each one-way trip separately, one unit per mile.
- Attendants in writing. One attendant is covered when the member’s provider certifies in writing that one is medically needed, or when the member is under 18 (8.324.7.12 NMAC). See escorts and caregivers.
The transportation rule also changed on September 1, 2026
HCA amended 8.324.7 NMAC, the NEMT rule, two weeks before the training. It adopted the changes on August 6, 2026, effective September 1, 2026:
| Rule | Before | Since September 1, 2026 |
|---|---|---|
| Written referral for travel outside the home community | Over 65 miles | Over 120 miles |
| Renewing that referral for ongoing trips | Every six months | Every 12 months |
| Rideshare companies | Not listed as providers | Eligible with a permit from the New Mexico Department of Transportation |
The rule now also says what 8.310.2 NMAC already said about pharmacy trips: they are not covered, except for members in their first seven days after release from a correctional facility. HCA cites Senate Bill 485 of the 2023 session as the authority for the changes.
What to do now
- Get the training materials if your staff missed the session. Questions go to the Medical Assistance Division at madinfo.hca@hca.nm.gov.
- Check every attendant trip. Mark the attendant box, write the attendant’s name, and keep the written attestation with the log.
- Match billed miles to logged miles on every one-way trip, and keep the odometer readings or route that support them.
- Pull a few past claims and time how long it takes to produce their records. A PERM request gives you 75 days.
- Update for the September 1 changes, starting with the 120-mile referral rule.
The NEMT trip documentation guide and the free trip log template cover each field an auditor checks. If you also drive Blue Cross and Blue Shield of New Mexico members, see its move to MTM Health on November 1, 2026.